sign in sign up
<<
Home , Navajo Dam

3°3- 6 3- re,e3 Ra 41/614-( rti,v,4( 111111 Aig-u ax.t ( 10(9 STATE UNIVERSITY Department of Zoology (602) 965-6518 Tempe, Arizona 85287-1501 FAX (602) 965-2519 28 December 1993 Mr. Robert D. Williams U. S. Fish and Wildlife Service 2060 Administration Building 1745 West 1700 South Salt Lake City, 84104-5110 Dear Bob: The following constitutes the joint comments of Paul C. Marsh, Center for Envi- ronmental Studies, and W. L. Minckley, Department of Zoology, Arizona State University on the U.S. Fish and Wildlife Service (hereafter FWS) Draft ENDANGERED FISHES CRITICAL HABITAT: BIOLOGICAL SUPPORT DOCUMENT (hereafter draft), dated 3 September 1993. Please note that we do not deal with the numerous typographical errors, miscita- tions, and errors and oversights in fact and interpretation some of which influ- ence generalizations offered in the document. Further, we have access to sub- stantial unpublished information on research and recovery efforts for all "big- river" fishes in the lower basin, much of which is not cited in the draft, but all of which is available for use upon request. We offer to assist in corrections and additions; please contact either or both of us if deemed approp- riate. Our most positive reaction to the draft is to support in concept the designation of all proposed reaches. Our reservations hinge primarily on the questionable and inconsistent application of the "primary constituent elements" and "additional selection criteria" [for , hereafter RBS, especially for the lower Colorado River basin. Primary constituent elements do not discriminate between areas that are proposed and those which are not. They apply to virtually any aquatic habitat in the system. The lack of information on why certain reaches are not proposed disallows evaluation of the significance of those which are, and essentially disallows evaluation of the suitability of any habitat for any species. The only justification for the additional selection criteria for Rl3S that we can identify (as stated in the draft, page 39) is the assumption that existing recovery plans for the other three species already encompass the criteria. They do not in any specific ways, and this especially applies to lower basin habitats which are scarcely treated. We urge the FWS to apply these "additional... criteria" to all four species in the final document. Based upon our collective knowledge of the biology of these fishes and their habi- tats, and our own application of "primary.., elements" and "additional... criteria," we recommend with brief supporting statements the following river reaches to also be included as proposed critical habitat. If the FWS chooses to accept our recommendations, we shall be pleased to provide greater detail. We treat the four species in the order of their obvious biological endangerment, most to least. Minckley and Marsh, page 2

BONYTAIL (hereafter BTC) 1) Colorado River mainstem and floodplain, Parker to the U.S.-Mexican border, AZ-CA—We propose addition of this reach since delivery of water to and Mexico insures water supply, at least, and the possibilities for cooperative recovery efforts within the region would be insured as well. In addition, this reach includes substantial land and water administered as na- tional wildlife refuges and thus (along with other habitats under different jurisdictions) clearly available for recovery actions. Historically, this part of the river supported the largest populations of BTC, Colorado squawfish, and RBS anywhere in the basin (Dill 1944; Follett 1961; Miller 1961; Minckley 1973,1985; Minckley et al. 1991). Draft pp. 81-87 describe part of this reach. 2) , Ashurst-Hayden Diversion (upstream from Florence, AZ) to the AZ-NM border—The substantial reach upstream from San Carlos Reservoir, like the Salt River mainstem, AZ, (see below), has no upstream impound- ments and is thus another "wild" river available for recovery. The reach upstream from Safford, AZ, has been designated a National Riparian Con- servation Area dedicated to perpetuation and enhancement of native flora and fauna, which is an obvious plus relative to recovery potentials for native fishes. Downstream from San Carlos Reservoir, changes in allocations will soon result in revised demands and patterns in water use. Such should provide additional recovery opportunities in the immediate future. In the past, BTC ascended the Gila mainstem to at least Ft. Thomas, AZ (Kirsch 1889). We have no specific recommendations on proposed critical habitat for BTC in the upper Colorado River basin, but suggest FWS reexamine reaches on both the Green and Colorado which lie between the short segments of pro- posed critical habitat. These constitute irreplaceable corridors for exchange of individuals and genes among the remaining populations, and are thus " critical."

RAZORBACK SUCKER 1) San .Juan River and lower Animas rivers, CO-NM—There seems ample bio- logical justification for including parts of the San Juan system upstream from Navajo Reservoir in critical habitat for RBS. Although no preserved specimens are known (Sublette et al. 1990), early anecdotal records likely are valid. Further, we do not understand the exclusion of the reach of San Juan River between Hogback Diversion, NM, and Navajo Dam, unless it is an assumption of unsuitability of that reach due to cold water temperatures or a possible conflict with sports fisheries, either of which may be changed in the future. We recommend its inclusion. 2) Colorado River mainstream and floodplain, to , AZ- CA-NV—Discussion of the proposed reach ("Colorado River - Parker Dam to ;" draft pp. 81-82) refers to recruitment of RBS there, but mis- Minckley and Marsh, page 3

cites Marsh and Minckley (1989) who clearly indicated that the recruits could not have been stocked fish and could only have been derived from upstream sources which included . RBS larvae have been taken from Lake Havasu (Marsh and Papoulias 1989). And, RBS larvae and adults that could only have come from Lake Havasu have been taken from the Central Arizona Project Canal (U.S. Bureau of Reclamation 1986, 1987). In addition, on-going recovery efforts in the lower basin already include aug- mentation, bay culture, and development of grow-out facilities associated with national wildlife refuges and Lake Havasu itself (C. 0. Minckley, FWS, pers. comm.).

3) Roosevelt Lake and lower Tonto Creek, its tributary from the northwest, and extend the proposed the Salt River reach from Canyon Creek to the confluence of the Black and White rivers, AZ-Minckley et al. (1991) re- viewed historic occurrences of RBS which included lower Tonto Creek, Ro- osevelt Lake, and the Salt River. Including Roosevelt Lake with its tributary streams is a logical progression of riverine habitat (which may well provide spawning and nursery sites) leading into lacustrine conditions that appear beneficial to large adults. Note that the draft map (p. 42), which terminates critical habitat at Canyon Creek (river mile [rrn] -43.5), is inconsistent with Table 2 (p. 43) that defines the upstream limit as "Apache Falls" (rm 60.5). The latter is more-or-less consistent with the text (p. 92) which gives the upstream limit as "US 60 bridge" (a bit downstream from Apache Falls). Note also that specific anecdotal records do exist for RBS from this reach ( Minck- ley et al. 1991) (stated otherwise in the draft pp. 92-93).

4) , AZ-UT--We are not convinced that Lake Powell has been ade- quately assessed as refugium habitat for RBS (Minckley et al. 1991), nor that it might not prove to be a valuable habitat in the future, at least for adults. It's exclusion seems inconsistent and perhaps reflects a capricious expres- sion of desire for garnefish management.

5) The lowermost , AZ-RBS are known to frequent Paria River, presumably for spawning (Suttkus et al. 1976; Minckley and Carothers 1980; unpubl. data). The Paria River mouth provides the only inflow of suffi- ciently warm water for reproduction by native fishes within the reach of the Colorado River (Minckley 1991).

6) Colorado River mainstem and floodplain, Imperial Dam to US-Mexican border, AZ-CA-The rationale for proposing this reach as critical habitat for RBS is the same as for ETC (above).

HUMPBACK CHUB ( HBC)--We have no specific recommendations for this species but suggest FWS reexamine the reaches on both the Green and Colorado rivers which lie between the short segments of proposed critical habitat. As for ETC (and all species, for that matter), these constitute important corridors for exchange of individuals and genetic material among the remaining populations of HBC, and thus are "critical." Minckley and Marsh, page 4

COLORADO SQUAWFISH (CSF)—We have few comments on the upper basin areas pro- posed as critical habitat for CSF. An absence of proposed critical habitat for the species in the lower basin is, however, unacceptable. We strongly recommend FWS consider the following reaches. 1) San Juan River and lower Animas rivers, CO-NM--As for RBS, there seems ample biological justification for including parts of the San Juan system above Navajo Reservoir in critical habitat for CSF. Specimens were preserv- ed during rotenone treatment of the reach now inundated by Navajo Reser- voir (Koster 1960). We do not understand exclusion of the reach of San Juan River between Farmington and Navajo Dam, NM (see RBS), and suggest it be included. 2) Roosevelt Lake and lower Tonto Creek, its tributary from the northwest, and the Salt River from Roosevelt Lake at least to the confluence of the Black and White rivers, AZ—This includes the recommendations to rescind the "ex- perimental, non-essential" designation of reintroduced stocks of CSF in the Salt River mainstem, so their reestablishment may be considered as a contri- bution to recovery. Ample documentation exists for large, viable populat- ions of CSF in this system in the past (Miller 1961; Minckley 1973, 1985, and references cited). 2) Verde River from Horseshoe Reservoir (including the reservoir) to Sulli- van Lake, AZ—See comments for "2)," immediately above, which apply here as well. 3) Gila River, Ashurst-Hayden Diversion (upstream from Florence, AZ) to the AZ-NM border—The rationale for proposing this reach as critical habitat for CSF is the same as for BTC (above). Again, ample documentation exists for former populations of CSF in this area (citations above). 4) Colorado River, to upper , AZ—It is markedly inconsistent with on-going discussions toward installation of multiple intake structures on Glen Canyon Dam and increasing interest in maintenance and enhancement of native fishes in the free-flowing, Grand/, that this reach be excluded from critical habitat designation for CSF. It is notable in this regard that the last wild CSF in the lower basin was taken in near Havasu Creek in 1975 (Smith et al. 1979). 5) Lower Colorado River and floodplain, Davis Dam to US-Mexican Border, AZ- CA-NV—We propose addition of this reach for some of the same reasons pro- vided above for BTC and RBS. We exclude only due to emphasis there for BTC and RBS recovery, and include the reach below Imperial Dam for the same reasons detailed above for RBS. A proposal by Arizona Game and Fish Department in the mid-1980's that CSF be stocked to develop a sport- fishery, and therefore to be designated "experimental, non-essential" has, to our knowledge, not yet been acted upon. We are further informed that FWS has requested that the proposal(s) be withdrawn, due in part to the length of Minckley and Marsh, page 5 time with no action since it(they) appeared. The lower portion of this reach includes the type locality for CSF. After reading the draft for specifics, mostly treated above, we re-read it for gen- eral content. In this broader sense we were unable to determine the rationale under which critical habitat was allocated among the four species. Perhaps a common rationale should not be expected, since each is treated separately, but a unifying thread among these fishes is that they are all classified as endangered; some cohesion should be evident, but it is not. For example, BTC is widely recog- nized as the most biologically imperiled of the four, yet only 15% of its presumed historic range is proposed as critical habitat, while nearly twice that proportion and three times as many river miles are proposed for CSF (clearly the least im- periled of the four). Why? We played a few statistical games based on the following dataset compiled directly from the draft to illustrate some of our concerns:

Columns 1 2 3 4 5

Spp. No. pp. in % Hist. mg. No. miles No. miles Assessment draft proposed proposed historic of endang. ETC 16 15 344 2293 1 RBS 60 52 1824 3508 2 HBC 17 28 379 1354 3 CSF 19 23 1148 4415 4

The strongest simple, linear correlation within these data (R2 = 0.77) exists betwe- en the number of pages in the draft allocated to each species (Col. 2) and the num- ber of river miles proposed (Col. 3), an obvious and expected result of habitat re- dundancy. We are dismayed, however, to find that no significant relationships exist between degree of endangerment (Col. 5) and any other variable (R2 consis- tently less than 0.16). Again we ask, why? Some of this variation obviously occurs in the exclusion of reservoir reaches in critical habitat proposed for some species (HBC, for obvious reasons; CSF less obvious), and their inclusion for others (BTC, RBS). Reasons for gaps in other species, especially BTC and HBC, in some cases for RBS (Lake Havasu), and the whole lower basin for CSF (presumably, in large part, a result of "experimental, non-essential" designations) are unexplained. Unless future populations are very large, we cannot conceive of either chub persisting for very long without perm- anent and reliable interconnections between and among populations, either by flowing river or by expensive and technically difficult, periodic augmentations between and among them. Where form permanent barriers, the latter methods may be applied, but if barriers do not exist, why not recognize the need and formalize the required linkages? Minckley and Marsh, page 6 In an even more general sense, what was the rationale for developing the last 34 pages of text? The section "Factors affecting Colorado River Endangered Fishes" is largely redundant to the previous 150+ pages, of variable detail (depending upon subject), and often strays from critical habitat as the focus of this document. If this information was used to delineate habitats proposed or excluded (and we pres- ume it was), it should be incorporated initially along with expanation and justific- ation for the decision-making process. Thus, for example, was the presence of barriers to fish movements made a part of the decision to include or exclude any segment? Did water management (deple- tions and releases, power marketing, water marketing) and state's entitlements become involved in biological decisions? If so, how and why? We recognize water temperature and sediment transport as limiting species' distributions, but did these things, in fact, also enter into the decisions to include or exclude any reach(es)? The review of contaminants is especially disturbing, since relationships of these possible problems with endangered species and their proposed critical habitats (if such can be identified in other than "what iP' scenarios) are almost totally ob- scured by an endless description of who did what, where, when, and what they found, with little or no regard for the significance of the findings, other than they might or might not be toxic! The section on "Channelization and Loss of Bottomlands" is remarkable in not recognizing the interrelationships of sediment starvation in a dammed system and channel changes downflow. Without sediment input, natural hydraulic conditions cannot exist. A general lack of recognition of the role and importance of sediment relationships to stream ecology permeates the document. Fish removal projects are adequately treated, but can be improved if completed by reference to similar activities the lower basin (Rinne and Turner 1991). The section on "Nonnative Fishes" (including, in part, 'Recreation,' relative to recreational fisheries) is disappointing, not that it is too superficial relative to the impact of aliens on natives, but in it's failure to thoroughly address potential solutions. We join FWS in its recognition of constraints on target species imposed by physical habitat alteration. However, it seems inconceivable in light of an ever increasing volume of reliable documentation that FWS would fail to acknowl- edge that, despite designation of critical habitat, none of the "big-river" fishes is likely to be recovered until and unless a policy of management against non- natives is adopted, implemented, and succeeds. It is noteworthy here (and in context of the section "Ongoing Recovery Efforts") that CSF and HBC have been federally listed as endangered since 1967 (more than a quarter of a century) and BTC has been so designated since 1980 (more than a decade), yet their status has continued to deteriorate and all three are clearly more biologically imperiled today than at their respective times of listing. Even the highly touted and well-funded upper basin Recovery Implementation Pro- gram (draft page 183) has failed during more than a third of its projected 15-year term and $10s of millions expended, to document substantive progress toward recovery. We define substantive as being measurable improvement in status of any of the four species of concern. Minckley and Marsh, page 7 The final section ("Biodiversity and Ecosystem Change") provides a refreshing philosophical perspective, but is superficial and may prove confusing to some. The lack of precise definition of "natural" biodiversity versus "unnatural" biodiv- ersity is an oversight that should be corrected. Clearly, the gross (natural plus unnatural) "biodiversity" (ichthyofaunally and otherwise) of Colorado River basin aquatic habitats is far greater today than before incursions and modifica- tion by technologic humans as a result of establishment of myriad non-native species, but this has accompanied by declines in the native fauna to the brink of extinction. We agree with FWS that "One important factor to consider... is the effects the added protection might have on other species..." (draft page 185). We would add that another, potentially more important factor to consider within the overall context of biodiversity and ecosystem change is the cumulative effect of continuing and unabated development of water resources (including nonnative fish stocking), the individual and collective impacts of which have resulted in the current im- periled status, with few exceptions, of the entire native fish fauna of the Colorado system. Continuation of these policies will inevitably result in faunal collapse. Thank you for the opportunity to review this document.

Sincerely,

W. L. Minckley, Professor Paul C. Marsh, Research Professor Department of Zoology Center for Environmental Studies Arizona State University Tempe, Arizona 85287-3211 Minckley and Marsh, page 8

LIThRATUREERATURE CITED

Dill, W. A. 1944. Fishery of the lower Colorado River. Calif. Fish Game 30: 109-211.

Follett, W. I. 1961. The freshwater fishes [of , Mexico]: their origins and affinities. Syst. Zool. 9(1960): 212-132

Kirsch, P. H. 1889. Notes on a collection of fishes obtained in the Gila River at Ft. Thomas, Arizona. Proc. U.S. Natl. Mus. 11: 555-558.

Koster, W. J. 1960. Ptvchocheilus lucius (Cyprinidae) in the San Juan River, . SW Nat. 5: 174-175.

Marsh, P. C. & W. L. Minckley. 1989. Observations on recruitment and ecology of razorback sucker: Lower Colorado River, Arizona-California-. Grt. Basin Nat. 49: 71-78.

Marsh, P. C. & D. Papoulias. 1989. Ichtyoplankton of Lake Havasu, a Colorado River impoundment, Arizona-California. Calif. Fish Game 75: 68-73.

Miller, R. R. 1961. Man and the changing fish fauna of the American Southwest. Pap. Mich. Acad. Sc!., Arts, Lett. 46: 365-404.

Minckley, C. 0. & S. W. Carothers. 1980. Recent collections of the Colorado squawfish and razorback sucker from the San Juan and Colorado rivers in New Mexico and Arizona. SW Nat 24: 686-687.

Minckley, W. L. 1973. Fishes of Arizona. Ariz. Game Fish Dept., Phoenix.

Minckley, W. L. 1985. Native fishes and natural habitats of U.S. Fish and Wildlife Service Region II, west of the Continental Divide. Rept. U.S. Fish Wildl. Serv., Ariz. St. Univ., Tempe.

Minckley, W. L. 1991. Native fishes of the Grand Canyon region: An obituary? Pp. 124-177, in, Colorado River Ecology and Dam Management. Natl. Acad. Press, Washington, D.C.

Minckley, W. L., P. C. Marsh, J. E. Brooks, J. E. Johnson, & B. L. Jensen. 1991. Management toward recovery of razorback sucker. Pp. 303-357, in, W. L. Minckley & J. E. Deacon, eds., Battle Against Extinction: Native Fish Management in the American West. Univ. Ariz. Press, Tucson.

Rinne, J. N. & P. R. Turner. 1991. Reclamation and alteration as management techniques and a review of methodology in stream renovation. Pp. 219-246, Ibid.

Smith, G. R., R. R. Miller, & W. D. Sable. 1979. Species relationships among fishes of the genus Gila of the upper Colorado River basin. Pp. 613-623, in, Proceedings of the First Annual Conference on Scientific Research in the National Parks, U.S. Natl. Pk. Serv. Trans. Proc. Ser. 5.

Sublette, J. E., M. D. Hatch, & M. Sublette. 1990. The Fishes of New Mexico. Univ. N. Mex. Press, Albuquerque. Minckley and Marsh, page 9

Suttkus, R. D., G. H. Clemmer, C. Jones, & C. R. Shoop. 1976. Survey of the fishes, mammals, and herpetofauna of the Colorado River in Grand Canyon. Grand Canyon National Park, Colo. R. Res. Ser. Contr. 34: 1-48.

U. S. Bureau of Reclamation. 1986. Central Arizona Project Granite Reef Aqueduct Fishery Investigations. Progress Report, 1986. U. S. Bur. Reclam., Ariz. Proj. Off., Phoenix. unpag- inated.

U. S. Bureau of Reclamation. 1987. Ibid., 1987. U. S. Bur. Reclaim, Ariz. Proi. Off., Phoenix. 36 pp. + appendices.